Anti Bribery Policy

VELMA Law places high importance on upholding responsible and fair business practices. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values.

VELMA Law therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter bribery.

Generally, anti-bribery and corruption laws prohibit making payments or gifts to government officials or another person in a powerful position in order to secure any improper business advantage. VELMA Law understands the importance of eliminating bribery and corruption and the role that discouraging bribery and corruption plays in creating a safer, more stable political and business environment.

No officer, employee or agent of VELMA Law may offer payments (or anything else of value) to a governmental official or potential client that will assist VELMA Law or its clients in obtaining or retaining business or securing any improper business advantage. Every VELMA Law officer, employee and agent is obligated to keep books, records and accounts that accurately and fairly reflect all transactions and the use of assets.

VELMA Law takes bribery and corruption very seriously and any employee found to be violating this policy will be subject to disciplinary action, which may include termination of employment. VELMA Law encourages employees to report any violations or suspicious activity that are described below. An employee’s failure to report known and suspected violations may lead to disciplinary action.

VELMA Law is constantly revising its training and procedures for addressing bribery and corruption in order to keep its employees and policies as effective as possible.

General Guidelines

No payment or gift of any kind may be made, promised or offered to a government official, political candidate, employee of a government owned entity, or client.

Paying excessive travel and entertainment expenses on behalf of a government official or client to obtain or maintain business can be considered a bribe.

An improper business advantage includes bribes to maintain existing business operations. For example, bribing an official to obtain or renew permits or certifications is illegal.

Payments or gifts made at the request of a government official / client to obtain or maintain business are forbidden. For example, if a government official indicates that he will ensure his agency does business with you in exchange for buying goods from his cousin’s company, that transaction is considered a bribe and is forbidden.

Payments made to an intermediary can be considered bribes. Therefore, VELMA Law requires that thorough background checks be undertaken on all intermediaries, and all intermediary payments are fully receipted.

Accurate books and records must be kept, and falsifying records to conceal a bribe is not allowed.

Red Flags

The following situations, among many other situations, could expose VELMA Law and the individuals involved to a risk of violation, and need to be reported to the management as set out below:

Requests or demands by a government official or client for a bribe.

Requests or suggestions by a government official or client that VELMA Law makes a charitable donation to a particular charity.

Requests by a government official or client for employment either on his or her own behalf or on behalf of another.

A government official or client who has a reputation for receiving questionable payments.

A request for an unusual or excessive payment, such as a request for over invoicing, unusual up front payments, unusual commissions, a request for payments to be made to a third party, to a foreign bank account, in cash or otherwise untraceable funds.

A proposed agent or representative refuses to provide written assurances that he or she will not make any improper payments.

Reporting a Violation

Any transaction, regardless of the amount, may give rise to violations of anti bribery and corruption laws and regulations and/or to VELMA Law’s policy. Thus, it is important that every employee understands the rules and reports any wrongdoing he or she notices as soon as possible. If an employee believes a violation is occurring, he or she should report it immediately to the management:

Any employee, who, in good faith, lawfully and truthfully, seeks advice, raises a concern or reports misconduct is doing the right thing. No matter how he/she chooses to report, as long as the report is made honestly and in good faith, VELMA Law will not take any retaliatory action against the employee. Allegations of retaliation will be investigated and appropriate action taken.